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able activities adjusted alien allocated allowed amount apply apportioned apportionment assets attributable bank basis beginning branch Code computed conduct considered controlled debt deduction defined derived described determined distribution dividend domestic earnings and profits effectively election engaged entity example excess exchange expense facts fair market value filed financing foreign corporation gain graph gross income held holder holding imposed income tax individual inter interest interest expense investment issued levy liabilities limitation loan loss meaning ment method nonresident obligation paid paragraph partnership payment percent period person poration portion principal production pursuant qualified real estate real property interest reason received regulations REMIC resident respect rules securities share shareholder sources Stat statement taxable income taxpayer term tion trade or business transaction treated trust U.S. real property United
Page 480 - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.
Page 120 - States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item or class of gross income.
Page 281 - This subparagraph relates to gross income derived from the sale of personal property produced (In whole or in part) by the taxpayer within the United States and sold within a possession of the United States, or produced (in whole or in part) by the taxpayer within a possession of the United States and sold within the United States.
Page 273 - Gains, profits and income from (1) transportation or other services rendered partly within and partly without the United States, or (2) from the sale of personal property produced (in whole or in part) by the taxpayer within and sold without the United States, or produced (in whole or in part) by the taxpayer without and sold within...
Page 354 - In the case of a nonresident alien individual the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States; and the proper apportionment and allocation of the deductions with respect to sources of income within and without the United States shall be determined as provided in section 119, under rules and regulations prescribed by the Commissioner with the approval of the Secretary.
Page 352 - The income of a nonresident alien individual which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States shall not be included in gross income and shall be exempt from taxation under this chapter.
Page 80 - ... is greater than the excess of the net long-term capital gain over the net short-term capital loss of the taxable year, the portion of each distribution which shall be a capital gain dividend shall be only that proportion of the amount so designated which such excess of the net long-term capital gain over the net short-term capital loss bears to the aggregate amount so designated.
Page 287 - States if— (A) the labor or services are performed by a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of 90 days during the taxable year...
Page 134 - ... there shall be included in the gross income an amount which bears the same relation to the total compensation as the number of days of performance of the labor or services within the United States bears to the total number of days of performance of labor or services for which the payment is made.
Page 134 - States as provided in subsection (a) (2) of this section; (3) Compensation for labor or personal services performed without the United States; (4) Rentals or royalties from property located without the United States or from any interest in such property...